From: Rahul Pendse <rpendse@trinityconsultants.com>

Sent: Tuesday, August 13, 2013 7:46 PM

To: Krivo, Stan

Cc: Kathryn.Maness@anadarko.com; Sara.Carlson@anadarko.com; 

Land, Eva; Fortin, Kelly

Subject: RE: Anadarko OCS Permit Application

Hello Stan,

Sara Carlson of Anadarko had a phone discussion with Kelly Fortin and Eva Land in the last week about 

the OCS PSD/Title V permit applications Anadarko is planning to submit in the near future. After the 

discussions with EPA, I was informed by Anadarko that they would like to apply for two permanent OCS 

PSD/Title V permit (i.e., renewable every five years) for the "Blackhawk" and the "Blackhornet" drillships. 

Also, Anadarko will be applying for a temporary 2-year PSD/Title V permit for the "Bob Douglas" drillship. 

I wanted to inform you about the recent changes since we had communicated previously about 

Anadarko's proposal for the temporary source permits for Blackhawk and Blackhornet drillships, 

For a temporary OCS permit application, the air dispersion modeling will be performed using the 

approach discussed in the emails below.

For the permanent OCS permit applications, the air dispersion modeling will be performed per air 

dispersion modeling protocol reviewed by you. For reference, I will provide you with a revised protocol 

with your comments incorporated and additional revisions based on our follow up phone discussions. 

Please let me or Sara Carlson know if you have any questions about the proposed air dispersion 

modeling approaches or if we could be of help.

Best Regards,

Rahul Pendse

-------------------------------------------------------------------------------------------------------------------------------------

Rahul Pendse│Managing Consultant│rpendse@trinityconsultants.com

Trinity Consultants│301 Main Street, Suite 900 │Baton Rouge, LA 70825

Office: 225-346-4003 │Fax: 225-346-4032│Cell: (714) 454-0518

From: "Krivo, Stan" <Krivo.Stanley@epa.gov>

To: Rahul Pendse <rpendse@trinityconsultants.com>, 

Cc: "Sara.Carlson@anadarko.com" <Sara.Carlson@anadarko.com>, "Kathryn.Maness@anadarko.com" 

<Kathryn.Maness@anadarko.com>

Date: 08/08/2013 01:32 PM

Subject: RE: Temporary OCS source Class I Modeling Approach

Rahul,

Given the proposed temporary OCS project will be in the same lease blocks as provided in the May 2013 Air 
Quality Modeling Protocol for the EGOM Completion and Maintenance Project, the previous provided (i.e., 

10/11/12 email below) procedure of modeling the worst-case emissions for both the drilling and support vessels 

from a single drilling vessel stack at the drilling vessel’s worst-case impact location would be acceptable.

Please note that a new temporary source OCS PSD application should consider and/or address:

- PM2.5 emissions (including secondary) and impacts, as appropriate 

- January 2012 court decision concerning the use of PM2.5 SIL and SMC 

- Use of CALPUFF for impact assessment

I assume that issue with the support vessel volume source modeling in the previous May 2013 modeling protocol is 

no longer of concern so your note concerning a separate email on this issue will not be sent.

Thanks...sjk

From: Rahul Pendse [mailto:rpendse@trinityconsultants.com] 

Sent: Thursday, July 18, 2013 4:21 PM

To: Krivo, Stan

Cc: Sara.Carlson@anadarko.com; Kathryn.Maness@anadarko.com

Subject: Re: Temporary OCS source Class I Modeling Approach

Stan,

Thanks for your time in discussing the air dispersion modeling protocol. Per our discussion, Anadarko will 

utilize previously approved approach of modeling worst-case project emissions (i.e., emissions from 

drilling and support vessels) from a single drilling vessel stack at the worst-case location (i.e., nearest 

from the Class I area receptor) for the proposed temporary (i.e., operations 2 year or less) OCS 

source. See your email below for reference. Please respond to this email when you get a chance. 

Thanks.

P.S. - I will send you a separate email summarizing our discussions about 'Volume Source Set Up' and 

associated emission rate.

Best Regards,

Rahul Pendse

-------------------------------------------------------------------------------------------------------------------------------------

Rahul Pendse│Managing Consultant│rpendse@trinityconsultants.com

Trinity Consultants│301 Main Street, Suite 900 │Baton Rouge, LA 70825

Office: 225-346-4003 │Fax: 225-346-4032│Cell: (714) 454-0518

----- Forwarded by Rahul Pendse/Trinity Consultants on 07/18/2013 03:11 PM -----

From: Stanley Krivo <Krivo.Stanley@epamail.epa.gov>

To: Rahul Pendse <rpendse@trinityconsultants.com>, 

Date: 10/11/2012 10:48 AM

Subject: Re: Class I Modeling Approach

Rahul,
For temporary OCS drilling sources the PSD regulation 40 CFR 52.21(i)(3) provides exemptions 

from the normal NAAQS and PSD increment analyses, pre- and post-construction monitoring, 

and additional impact analyses requirements. To qualify for the exemption the project allowable 

emission must impact no Class I area and no area where the applicable increment is known to be 

violated.

My understanding is that your proposed OCS source would be temporary, have the same PSD 

pollutants, and be located in the same general area as that for ENI and BHP Billiton permit 

applications. Because of the distance to the nearest Class I area and the fact that the Class I area 

impacts of concern are the AQRV and PSD increments (i.e., 24-hour and annual averaging 

periods), the procedure of modeling worst-case project emissions (i.e., emissions from drilling 

and support vessels) from a single drilling vessel stack at the worst-case location used in the ENI 

and BHP Billiton applications would be acceptable. [Note this modeling procedure may not be 

acceptable for non-temporary OCS PSD applications.]

Please let me know of any questions.

...sjk

Stanley J. Krivo

US Environmental Protection Agency, Air Planning Branch

Atlanta Federal Center, 61 Forsyth Street, SW

Atlanta, Georgia 30303

404/562-9123 (Phone) 404/562-9019(Fax)

Rahul Pendse ---10/10/2012 06:21:31 PM---Stan, Thanks for your time to discuss Class I modeling 

approach with me. To

From: Rahul Pendse <rpendse@trinityconsultants.com>

To: Stanley Krivo/R4/USEPA/US@EPA

Date: 10/10/2012 06:21 PM

Subject: Class I Modeling Approach

Stan,

Thanks for your time to discuss Class I modeling approach with me. To further clarify our discussion 

about Class I modeling yesterday, I was proposing to use the modeling approach specified in the 

attached determinations based on which OCS-EPA-R4007 and OCS-EPA-R4008 were approved.

 Please refer to Section 9.4.2 of the attached document

 Please refer to Section 7.2.2 of the attached document 

Let me know if you would like to discuss further after you get a chance to review the attached documents. 

Thanks again and I look forward to hearing from you. Have a good rest of the week.

Best Regards,

Rahul Pendse

Managing Consultant | Trinity Consultants 
Phone: 949-296-4100 Ext. 106 | Cell: 714-454-0518

________________________________________________________________

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[attachment "Eni_PD_SOB_8_31_2011.pdf" deleted by Stanley 

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"2012_03_30_BHPB_Preliminary_Determination.pdf" deleted by 

Stanley Krivo/R4/USEPA/US] 

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Received this in error, please contact the sender and delete the material 

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